Application of Combined Reporting, Allocation Rules Vary by State, Impose New Burdens on Non-U.S. Companies

Daily Tax Report: State provides authoritative coverage of state and local tax developments across the 50 U.S. states and the District of Columbia, tracking legislative and regulatory updates,...

An increasing number of states are requiring combined reporting as they look to combat income shifting across state lines. These changes often impose new requirements on non-U.S. corporations, including some that are not subject to federal tax. In this interview, Dennis Rimkunas of Jones Day answers questions about how the states approach allocation and apportionment issues affecting non-U.S. companies, including their different applications of the so-called 80/20 analysis and specific rules for “tax haven companies.”